associate principal environmental planner design ... · 6/21/2012  · here is the mou from jeremy....

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From: Hofreiter, Larry To: Boparai, Poonam Subject: RE: Rugged AQ & Climate Change Review Date: Thursday, June 21, 2012 2:36:43 PM Attachments: Attachment A Pre-App Summary Letter.pdf Here ya go... I couldn't find it in Documentum either. Larry Hofreiter County of San Diego Department of Planning and Land Use 5201 Ruffin Road, Suite B, San Diego, CA 92123 Telephone: (858) 694-8846 /Fax: (858) 694-3373 [email protected] -----Original Message----- From: Boparai, Poonam Sent: Thursday, June 21, 2012 2:35 PM To: Hofreiter, Larry Subject: RE: Rugged AQ & Climate Change Review Larry - Turns out I do want to look at the scoping language. Can you send me the link to the AQ attachment in the Scoping letter. I couldn't find it in Documentum. -----Original Message----- From: Hofreiter, Larry Sent: Thursday, June 21, 2012 1:16 PM To: Boparai, Poonam Subject: RE: Rugged AQ & Climate Change Review Ooops.... sorry, I must have misunderstood you. But if you could get it to me today or tomorrow, I'll click it off for you. Let me know. Thanks and sorry for the mess-up. Larry Hofreiter County of San Diego Department of Planning and Land Use 5201 Ruffin Road, Suite B, San Diego, CA 92123 Telephone: (858) 694-8846 /Fax: (858) 694-3373 [email protected] -----Original Message----- From: Boparai, Poonam Sent: Thursday, June 21, 2012 1:14 PM To: Hofreiter, Larry Subject: RE: Rugged AQ & Climate Change Review Hi Larry, I had indicated in my email that I can get it done by the end of next week! I can still complete the reviews tomorrow. I'll be offsite so would you be able to check off the task for me once done? Thanks, Poonam -----Original Message----- From: Hofreiter, Larry

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Page 1: Associate Principal Environmental Planner Design ... · 6/21/2012  · Here is the MOU from Jeremy. Hopefully this will do the trick for DPLU review of the Rugged Solar LLC Air Quality

From: Hofreiter, LarryTo: Boparai, PoonamSubject: RE: Rugged AQ & Climate Change ReviewDate: Thursday, June 21, 2012 2:36:43 PMAttachments: Attachment A Pre-App Summary Letter.pdf

Here ya go... I couldn't find it in Documentum either.

Larry HofreiterCounty of San Diego Department of Planning and Land Use5201 Ruffin Road, Suite B, San Diego, CA 92123Telephone: (858) 694-8846 /Fax: (858) [email protected]

-----Original Message-----From: Boparai, PoonamSent: Thursday, June 21, 2012 2:35 PMTo: Hofreiter, LarrySubject: RE: Rugged AQ & Climate Change Review

Larry - Turns out I do want to look at the scoping language. Can you send me the link to the AQattachment in the Scoping letter. I couldn't find it in Documentum.

-----Original Message-----From: Hofreiter, LarrySent: Thursday, June 21, 2012 1:16 PMTo: Boparai, PoonamSubject: RE: Rugged AQ & Climate Change Review

Ooops.... sorry, I must have misunderstood you. But if you could get it to me today or tomorrow, I'llclick it off for you.

Let me know. Thanks and sorry for the mess-up.

Larry HofreiterCounty of San Diego Department of Planning and Land Use5201 Ruffin Road, Suite B, San Diego, CA 92123Telephone: (858) 694-8846 /Fax: (858) [email protected]

-----Original Message-----From: Boparai, PoonamSent: Thursday, June 21, 2012 1:14 PMTo: Hofreiter, LarrySubject: RE: Rugged AQ & Climate Change Review

Hi Larry,

I had indicated in my email that I can get it done by the end of next week! I can still complete thereviews tomorrow. I'll be offsite so would you be able to check off the task for me once done?

Thanks,Poonam

-----Original Message-----From: Hofreiter, Larry

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Sent: Thursday, June 21, 2012 1:04 PMTo: Boparai, PoonamSubject: Rugged AQ & Climate Change Review

Hi Poonam,

Just a friendly reminder that the Rugged Solar AQ and Climate Change studies are still outstanding.... Do you think you'll have comments to me sometime either today or tomorrow 06/22/12?

Let me know... Thanks.

Larry HofreiterCounty of San Diego Department of Planning and Land Use5201 Ruffin Road, Suite B, San Diego, CA 92123Telephone: (858) 694-8846 /Fax: (858) [email protected]

-----Original Message-----From: Boparai, PoonamSent: Tuesday, June 19, 2012 9:45 AMTo: Hofreiter, LarrySubject: RE: MOU for Rugged

Hi Larry,

Given my current workload, I'd say I can get the review done by end of next week. I may be able toget it done earlier but if you can get me an assignment with that due date, that would be great!

Thanks,Poonam

________________________________________From: Hofreiter, LarrySent: Friday, June 15, 2012 10:17 AMTo: Boparai, PoonamSubject: FW: MOU for Rugged

Hi Poonam,

We have the MOU for the AQ and Climate Change... Can you begin reviewing these reports? When youdo, when do you think you'll have comments to me? Let me know so I can get an assignment in thesystem for you.

Thanks so much! :)

Larry HofreiterCounty of San Diego Department of Planning and Land Use5201 Ruffin Road, Suite B, San Diego, CA 92123Telephone: (858) 694-8846 /Fax: (858) [email protected]

-----Original Message-----From: Patrick BROWN [mailto:[email protected]]Sent: Friday, June 15, 2012 8:29 AMTo: Hofreiter, LarrySubject: Fwd: MOU for Rugged

Larry,

I will give you soitec signed copy at meeting.

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Pb

Begin forwarded message:

From: "Page, Michael (EDAW)" <[email protected]<mailto:[email protected]>>Date: June 15, 2012 7:09:57 AM PDTTo: Patrick BROWN <[email protected]<mailto:[email protected]>>Cc: Jeremy Louden <[email protected]<mailto:[email protected]>>, "Maddux,William" <[email protected]<mailto:[email protected]>>Subject: FW: MOU for Rugged

Patrick,

Here is the MOU from Jeremy. Hopefully this will do the trick for DPLU review of the Rugged Solar LLCAir Quality Report. Let me know if you need anything else and how it goes with Larry today.

Take Care,

Mike

Michael L. Page, AICPAssociate Principal Environmental PlannerDesign + PlanningDirect + 1 619 684 6940 Main + 1 619 233 [email protected]<[email protected]>

AECOM1420 Kettner Boulevard, Suite 500, San Diego CA 92101 USAT + 1 619 233 1454 F + 1 619 233 0952www.aecom.com

From: Jeremy Louden [mailto:[email protected]]Sent: Friday, June 15, 2012 7:05 AMTo: Page, Michael (EDAW)Cc: Maddux, WilliamSubject: MOU for Rugged

Attached is the MOU and letter.

Jeremy Louden, PrincipalLdn Consulting, Inc.phone 760-473-1253fax 760-689-4943446 Crestcourt LaneFallbrook, CA 92028Noise, Air Quality & GHG

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ATTACHMENT A MUP APPLICATION SCOPING INFORMATION

3992-11-018 (MPA) RUGGEDSOLAR

A. PLANNING ANALYSIS:

1. Project Description: A detailed Project Description is required. The report shall detail the following information: general project description, location, consistency with CA Global Warming and AB 32 compliance information, grading information, purpose and need of project, description of activities, traffic and circulation, groundwater usage, security, electrical transmission and distribution onsite and offsite, lighting, signage, utilities, existing conditions, and site photographs. The following items should also be included in the project description:

A draft-decommissioning plan should be provided to the County that would describe how the project would be decommissioned. The project site should be left in a manner that is consistent with what could be permitted by right pursuant to the Zoning Ordinance Section 6952b.3.d. This plan should identify a potential financial mechanism for the plan, but does not need to actually provide the financial mechanism.

The project description shall include the Operation and Maintenance component for this project with the number of Average Daily Trips (ADT), in order to document if there are any direct impacts to the roadway network generated from the implementation of this project. Cumulative impacts will be mitigated by payment of the Transportation Impact Fee (TIF). In order to determine if a Traffic Analysis is required, please review the Transportation and Traffic Guidelines for Determining Significance and Report Format and Content Requirements. Additional information can be obtained in the following link: http://www.sdcounty.ca.gov/dplu/docs/Traffic_Guidelines.pdf

Water Usage for the project: Provide in the project description a water demand assumption as well as an identified water source for construction and ongoing cleaning and site maintenance. Any water that is not obtained from a private non-public agency will require review for a Groundwater Extraction Major Use permit. See Attachment D.

Discuss that the recycling during construction will be in compliance with the County of San Diego Construction Demolition and Debris Management Plan requirements in accordance with County Ordinance 68.508-68.518.

2. Plot Plan: A detailed plot plan is required that complies with DPLU Form #90, and should include these additional items:

Details of proposed structures, square footages of all structures in a cumulative table, lot coverage calculations, building setbacks, substations, transformer rooms, utility and County rights of ways,

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3992-11-018 (MPA) 2-26 October 25, 2011 Rugged Solar

generation tie lines, existing structures, and any additional elevations. Show solar panel arrays and proposed internal 24’ wide improved driveway widths (Per County Fire Code).

Include all existing onsite wastewater disposal systems and groundwater wells on the plot plan. If there is none that are contained within the property boundaries, the plans need to state it.

Include all existing wells on the plot plan. All wells must be labeled to reflect the proposed groundwater use. The destruction of any well requires a destruction permit and inspection of the completed work by the Department of Environmental Health.

Show the ultimate right-of-way and the ultimate building setback limits. At the time of the construction/improvements, any proposed facilities shall be relocated at the sole cost of the applicant to the satisfaction of the Director of Public Works.

Show lines of inundation to the limits of the 100-year flood along the watercourse, which flows through the property, labeled ―Subject To Inundation By The 100-Year Flood.‖

Show existing and proposed property lines (PL), call out Centerline of Old Highway 80; call out edge of pavements (EOP) and dimensions from centerlines to existing & proposed PL, EOP, also include all public road and driveway cross-sections.

The project access points from a public road shall be shown on the Plot Plan and Preliminary Grading Plan. The County prefers that the project take access from McCain Valley Road for both phases of the project.

On the plot plan and preliminary grading plan, indicate the point of interconnection until it reaches the public utility. Any offsite generation tie lines need to be covered by the plot plans and project description because they need to be covered by the MUP.

Proof of legal access will be required for all parcels. A Preliminary Title Report with Schedule B Attachments should be provided.

Indicate all Assessor Parcel Numbers and boundary lines for each phase.

Plot all open space easements and indicate permanent fencing around these areas.

The County Fire Authority (CFA) requirements should be implemented on the plot plan. Consult with the CFA as indicated below in Section I.

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3992-11-018 (MPA) 3-26 October 25, 2011 Rugged Solar

Implement all circulation, gate, and other improvements as required by the County Fire Authority and County Fire Code 96.1.503 through 605.11.4.4. as follows:

Sec. 503.2.1 Dimensions. (a) Fire apparatus access roads shall have an unobstructed improved width of not less than 24 feet… (b) All fire apparatus access roads shall have an unobstructed vertical clearance of not less than 13 feet 6 inches… Sec. 503.2.3 Surface. Fire apparatus access roads shall be designed and maintained to support the imposed loads of fire apparatus (not less than 50,000 lbs.) and shall be provided with an approved surface so as to provide all-weather driving capabilities. Sec. 503.2.4 Turning radius. The turning radius of a fire apparatus access road shall comply with the County public and private road standards approved by the Board of Supervisors. The turning radius for a private driveway shall be a minimum of 28 feet, as measured on the inside edge of the improvement width or as approved by the fire code official. Sec. 503.2.5 Dead ends. All dead-end fire access roads in excess of 150 feet in length shall be provided with approved provisions for turning around emergency apparatus… Sec. 503.6 Security gates. No person shall install a security gate or security device across a fire access roadway without the fire code official's approval. An automatic gate across a fire access roadway or driveway shall be equipped with an approved emergency key-operated switch overriding all command functions and opening the gate…

Sec. 605.11.4 Ground-mounted photovoltaic arrays: Ground-mounted photovoltaic array installations shall meet the requirements of sections 605.11.4.1 through 605.11.4.4.

The driveway access and should be designed per County of San Diego Design Standard DS-17, DS-18, or DS-19.

3. Sight Distance: The project access points from a public road will need to meet Sight Distance Requirements per the County Public Road Standards, Section 6.1 Table 5 prior to recommendation for approval. In order to provide an unobstructed view for safety while exiting the property and accessing a public road from the site, and to comply with the Design Standards of Section 6.1.(E) of the County of San Diego Public Road Standards, an unobstructed sight distance shall provided to the County to be verified as indicated below:

http://www.sdcounty.ca.gov/dpw/docs/PublicRoadStandards.pdf

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3992-11-018 (MPA) 4-26 October 25, 2011 Rugged Solar

a. A registered civil engineer, a registered traffic engineer, or a licensed land surveyor provide a certified signed statement that: ―Physically, there is a minimum unobstructed sight distance based upon prevailing traffic speeds in both directions along Palm Canyon Drive from the project’s access is achievable per Section 6.1.E of the County Public Road Standards (approved July 14, 1999).‖

b. If the lines of sight fall within the existing public road right-of-way,

the engineer or surveyor shall further certify that: Said lines of sight fall within the existing right-of-way and a clear space easement is not required.‖

B. PRELIMINARY GRADING PLANS: There is an undisclosed amount of grading for the site. A Preliminary Grading Plan must be completed in accordance with the Preliminary Grading Plan Guidelines, which can be found online http://www.sdcounty.ca.gov/dplu/docs/ZC034.pdf. Preliminary grading plans must be submitted at the beginning of the discretionary permit process in order to address concerns regarding the long-term protection and improvement of stormwater quality. Structural BMPs are difficult to add to the completed design of a private development project without causing significant changes to the project's character. As such, the earlier in the design process stormwater facilities are considered, the greater the chance a successful and efficient design can be accomplished. C. SCOPE FOR COMMUNITY CHARACTER & LAND USE ANALYSIS: Community Character Analysis: A community character analysis shall be prepared for the proposal. This analysis shall include maps that indicate the surrounding land uses that exist in the area and the following additional information: 1. An evaluation of the compatibility of the scale and mass of the proposed project

with the surrounding area:

This evaluation shall include information, which compares square footage, heights, lot sizes, required earthwork and occupancy rates of other uses near the proposed project.

The architectural style of the structures and their site utilization shall be related to the manner in which surrounding properties have developed.

Landscaping shall be discussed in light of the ability of the plantings to soften the exterior appearance and relative massiveness of the proposed structures.

A graphic showing all residences/land uses within proximity of the project site.

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3992-11-018 (MPA) 5-26 October 25, 2011 Rugged Solar

2. Other physical impacts resulting from the nature of the operations:

This evaluation shall include the type of activities to be conducted, the time of day during which the various operations will occur, the days of the week the facility will be used, and the number of peoples involved.

This information shall define any potential impacts associated with this intensification of use of the site as well as providing a baseline for the analysis of noise, traffic, lighting or other related impacts.

3. The potential for subsequent changes to the regional environmental setting

resulting from similar additional requests encouraged by the now altered community character or what physical limitations would not permit other property owners from following suit.

4. The analysis shall include a Draft set of the Major Use Permit Findings pursuant

to Section Section 7359.a of the Zoning Ordinance, for findings required for major use permits. Draft Major Use Permit findings to ensure the feasibility of proceeding with the project. Actual findings are made by decision makers, but the draft findings enable DPLU and the public an opportunity to see if the findings could be made by the decision maker. (SEE MAJOR ISSUE #3)

The following findings in support of the granting of the Major Use Permit shall be made: (a) The location, size, design, and operating characteristics of the proposed

use will be compatible with adjacent uses, residents, buildings, or structures with consideration given to

1. Harmony in scale, bulk, coverage, and density 2. The availability of public facilities, services, and utilities 3. The harmful effect, if any, upon desirable neighborhood character 4. The generation of traffic and the capacity and physical character of

surrounding streets 5. The suitability of the site for the type and intensity of use or

development which is proposed 6. Any other relevant impact of the proposed use

(b) The impacts, as described in Findings (a) above, and the location of the proposed use will be consistent with the San Diego County General Plan.

(c) That the requirements of the California Environmental Quality Act have

been complied with.

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3992-11-018 (MPA) 6-26 October 25, 2011 Rugged Solar

Land Use Consistency Analysis: The purpose of the study is to examine and provide evidence that the proposed project is consistent with the following: (1) All applicable land use plans by showing consistency with their goals and policies not limited to but including General Plan, Community Plans, Specific Plans, Airport Land Use Compatibility Plans, and any other pertinent land use plan. (2) Compliance with the County Board of Supervisor Land Development I-Policies. (3) Compliance with all ordinances that pertain to land development such as Groundwater, RPO, Noise, Zoning. If separate reports have been drafted to cover those issues, the report may make reference to those separate technical studies. (4) The analysis should also cover compatibility with any future land use plans such as the East County MSCP when applicable. The analysis should cover each plan General Plan and Community Plan policy and implementation measure that is relevant to the project. All policies and implementation measures that are not relevant to the proposed project should be listed in a separate table as an appendix to the study. The table should indicate that they were reviewed, but were considered not applicable. The Land Use Analysis shall detail how the project complies with all of the following:

Goals and Policies of the recently adopted General Plan Update.

Goals and Policies of the Mountain Empire Subregional Community Plan, specifically the Boulevard Community Plan.

All County Ordinances, including but not limited to the following: Resource Protection, Stormwater and Discharge, Noise, Lighting, and Zoning (See Above #4).

General Plan Consistency: As currently designed, the proposed project does not comply with several General Plan policies and the Department of Planning and Land use may recommend denial if the project is not redesigned. These policies are identified below. The applicant should review these policies and redesign the project so that it complies with the County’s newly adopted General Plan:

LU-5.3 Rural Land Preservation: Ensure the preservation of existing open space and rural areas (e.g., forested areas, agricultural lands, wildlife habitat and corridors, wetlands, watersheds, and groundwater recharge areas) when permitting development under the Rural and Semi Rural Land Use Designations. Analysis: The site is designated as Rural Lands 80 (RL80), and the project appears to be impacting a large area that would qualify as wetland under the County’s Resource Protection Ordinance. The project should be redesigned to ensure the preservation of this existing wetland and any other wildlife habitat corridors that may be found in the area. LU-6.6 Integration of Natural Features into Project Design: Require incorporation of natural features (including mature oaks, indigenous trees, and rock formations) into proposed development and require avoidance of sensitive environmental resources. Analysis: The project would be a solar facility containing numerous individual concentrating photovoltaic (CPV) trackers that are up to 35 feet tall and 48 feet wide on approximately 300-acres of land. Based on the submitted plot plan, there is no evidence that the proposed development incorporated any natural features into its

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3992-11-018 (MPA) 7-26 October 25, 2011 Rugged Solar

project design or avoided sensitive environmental resources on-site. The project should be redesigned to comply with this policy. LU-10.2 Development-Environmental Resource Relationship: Require development in Semi-Rural and Rural areas to respect and conserve the unique natural features and rural character, and avoid sensitive or intact environmental and hazard areas. Analysis: Based on the submitted plot plan, there is no evidence that the proposed development is conserving the project sites unique natural features or avoiding sensitive or intact environmental and hazard areas. The project should be redesigned to comply with this policy. COS-11.1 Protection of Scenic Resources: Require the protection of scenic highways, corridors, regionally significant scenic vistas, and natural features, including prominent ridgelines, dominant landforms, reservoirs, and scenic landscapes. Analysis: The project site is located approximately 1.5 miles north of Interstate 8 (County Scenic Highway) and may impact the view-shed of this scenic highway. Additionally, the area can be characterized as having prominent ridgelines, dominant landforms and scenic landscapes. Locating over 3,000 individual concentrating photovoltaic (CPV) trackers that are up to 35 feet tall and 48 feet wide on approximately 600-acres of land in this area is likely to impact the scenic resources of the area. The project should be redesigned to ensure scenic landscapes, including views from Interstate 8, are not adversely impacted. COS-11.3 Development Siting and Design: Require development within visually sensitive areas to minimize visual impacts and to preserve unique or special visual features, particularly in rural areas, through the following: • Creative site planning • Integration of natural features into the project • Appropriate scale, materials, and design to complement the surrounding natural landscape • Minimal disturbance of topography • Clustering of development so as to preserve a balance of open space vistas, natural features, and community character. • Creation of contiguous open space networks Analysis: Given the visual sensitivity of the area, the project should be redesigned to utilize the techniques listed above. The applicant may want to consider utilizing smaller, less prominent CPV trackers to ensure the appropriate scale, materials and design complement the surroundings of the natural landscape. COS-11.7 Underground Utilities: Require new development to place utilities underground and encourage ―undergrounding‖ in existing development to maintain viewsheds, reduce hazards associated with hanging lines and utility poles, and to keep pace with current and future technologies. Analysis: The project proposes an overhead 69kV distribution line from the project site for approximately 1.5 miles south, over Interstate 8 to the new Boulevard substation. If

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3992-11-018 (MPA) 8-26 October 25, 2011 Rugged Solar

this is a new utility line, it should be placed underground. If not, the applicant should clarify that it’s an existing utility line and explain why it should not be placed underground. In addition to redesigning the project to comply with the County’s General Plan, please include a Community Character / General Plan Consistency Analysis to demonstrate how the project complies with the County’s General Plan and Boulevard Community Plan policies. Boulevard Community Plan Consistency: As currently designed, it appears that the project would not comply with several Boulevard Community Plan policies. At this time, County staff is working on revisions to the Boulevard Community Plan. However, until the Community Plan has been formally amended by the County Board of Supervisors, the project is responsible for demonstrating compliance all of the Boulevard policies. Staff has identified the following policies as being particularly difficult to comply with, given the projects current design. Boulevard Community Plan Policies: Policy LU: 1.1.1, 1.2.2, 1.3.2, 6.1.2, 6.1.3, and 6.1.4.

Report Format: The report should have the following Format: (1) Brief project Description, describe physical Setting. (2) Land Use analysis as discussed above, including land use maps. (3) Community Character analysis that includes figures that show the surrounding land uses and describes how this project would or would not be harmonious, or would diminish the character of its surroundings. Photographs of the surrounding community and land uses would be helpful to paint the picture. (4) Draft MUP Findings. Note: avoid redundant information that is already described in detail in the project description of the report, and the main project description report. D. MEMORANDUMS OF UNDERSTANDING: The County of San Diego’s CEQA guidelines require that environmental technical studies be prepared by a consultant from the County’s CEQA Consultant List, which can be found on the County of San Diego’s website at: http://www.co.san-diego.ca.us/dplu/procguid.html (item number 4 under ―General Guidance‖). No list is maintained for hydrology and stormwater management planning. With the exception of minor stormwater management plans, only registered engineers registered in the State of California shall be permitted to submit hydrology/drainage studies and only registered engineers or Certified Professionals in Storm Water Quality certified by CPESC, Inc., or an equivalent entity approved by the Director of Public Works, shall be permitted to submit stormwater management plans. Applicants are responsible for selecting and direct contracting with specific consultants from the County’s list to prepare CEQA documents for private projects. Prior to the first submittal of a CEQA document prepared by a listed consultant for a private project, the applicant, consultant, consultant’s firm (if applicable) and County shall execute the attached Memorandum(s) of Understanding (MOU). The responsibilities of all parties involved in the preparation of environmental documents for the County (i.e. applicant, individual CEQA consultants/sub-consultants, consulting/sub-consultant firms, and County) are clearly established in the MOU for each requested applicable study. The clear identification of roles and responsibilities for all parties is intended to contribute to

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3992-11-018 (MPA) 9-26 October 25, 2011 Rugged Solar

improved environmental document quality. The MOU can be found on the Department’s website at: http://www.co.san-diego.ca.us/dplu/procguid.html (item number 12 under ―General Guidance‖) and can be downloaded in word format at http://www.sdcounty.ca.gov/dplu/docs/MOU.doc Copies must be made and signed by the applicant, consultant and firm (if applicable) for each of the following requested subject area technical studies:

Air Quality • Fire Protection Planning

Archaeological Resources • Land Use Planning

Biological Resources

Noise

Visual Analysis E. SCOPE FOR VISUAL RESOURCES & AESTHETICS: The Department of Planning and Land Use has completed review of your project application and has determined that the project may adversely affect visual resources (See also Major Issue #2). Visual resources can include narrow or expansive views, can be views from one site or from a series of sites (as along a scenic highway), and can be viewed from above, at eye level, or from below. A particular thing that defines a community or a region’s character and identity is also a scenic resource. The aesthetic value of visual resources is not limited to open space and rural lands, but can also be held in historic structures and districts, architectural design, streetscapes and manufactured landscapes. These valuable aesthetic elements of the human-made environment can be found throughout the unincorporated County, even though it is mostly undeveloped. It has been determined that a visual resource report and photo simulations of the project should be prepared as follows:

1. The report must follow the format given in the County’s Report Format and Content Requirements for Visual Resources, which can be found at: http://www.sdcounty.ca.gov/dplu/docs/Visual_Report_Formats.pdf. The report must evaluate potentially adverse impacts to the environment according to the County’s Guidelines for Determining Significance for Visual Resources, which can be found at: shallhttp://www.sdcounty.ca.gov/dplu/docs /Visual_Guidelines.pdf The report must be prepared by a visual resources analyst who is on the County’s approved consultant list for completing Visual Resource Reports.

2. The photo simulations shall be prepared following the Photo Simulation

Guidelines that are attached to the Report Format and Content Requirements for Visual Resources available at the following web page: http://www.sdcounty.ca.gov/dplu/docs/Visual_Report_Formats.pdf . The photo simulations shall show views that can be determined by the visual consultant and DPLU staff. Please do not prepare any visual simulations or determine any Key Observation Points (KOP) without approval from DPLU. Some of the views should be vantage points as indicated below:

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3992-11-018 (MPA) 10-26 October 25, 2011 Rugged Solar

Interstate 8 Looking east

Interstate 8 Looking west

Directly adjacent to the project site from different positions.

Several Pictures shall be provided where a visual simulation would not be viable:

From any place where the public could view the project from an elevated position

Additional photos that would make sense to show vantage points of the project.

From State Park, public lands, and any recreational areas that the project site can be seen.

And any additional approved by the Department Photo-simulations must be supplied by a visual resources analyst who is on the County’s approved consultant list for completing Visual Resource Reports.

3. Provide a Glint and Glare Analysis. 4. General Plan Consistency Analysis (see Major Issue #1). The Memorandum of Understanding must be executed by the applicant and consultant and subsequently submitted with the first iteration review. F. SCOPE FOR AIR QUALITY ANALYSIS: Project Information: The project has the potential to significantly contribute to the violation of an air quality standard or significantly contribute to an existing or projected air quality violation, primarily related to grading. Therefore, the project is required to discuss the project’s potential impacts to air quality by preparing an air quality analysis report. General Information: Based on the potential impacts the project may have on air quality an air quality analysis is required. The air quality analysis must be completed using the County’s Air Quality Analysis Format Guidelines (attached) which can be found on the World Wide Web at http://www.sdcounty.ca.gov/dplu/Resource/docs/3~pdf/AQ-Report-Format.pdf. Emissions of pollutants of concern from the proposed project may occur from construction activities and operations (traffic associated with the project). In general, emissions from construction activities include:

Respirable particulate matter (PM10 and PM2.5) from grading; trenching associated with underground utilities; and combustion emissions from mobile and stationary sources (generators)

Products of combustion, including hazardous air pollutants, from construction equipment and stationary sources (generators);

Products of combustion, including hazardous air pollutants, from mobile sources

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resulting from traffic delays during construction. The principle emissions from operations, (e.g. build-out), result from traffic throughout the project site and beyond. Queuing of vehicles at lights can result in concentration of emissions called ―hot spots.‖ Given the present status of the San Diego Air Basin, of principal concern are emissions of carbon monoxide and VOCs in these areas. In order to adequately assess emissions during build-out of the area, the analysis should assess level of service impacts along major roadways. Additionally, the following issues should be addressed as a part of the air quality analysis: 1. Would the proposed project conflict or obstruct the implementation of the San

Diego Regional Air Quality Strategy (RAQs) or applicable portions of the State Implementation Plan (SIP)?

2. Would the proposed project result in emissions that would violate any air quality

standard or contribute substantially to an existing or projected air quality violation?

3. Since San Diego County is presently in non-attainment for the Federal and/or

State Ambient Air Quality Standards for Ozone (O3) and Particulate Matter Less than 10 Microns (PM10), would the proposed project result in a cumulatively considerable net increase of PM10 or exceed quantitative thresholds for 03 precursors, oxides of nitrogen (NOX) and Volatile Organic Compounds (VOCs)? The analysis should also provide a detailed discussion on cumulative impacts, framed in light of Past, Present and Reasonable Anticipated Future Projects in the Project Area. This should include a discussion on other projects contribution of PM10 and ozone precursors.

4. Would the proposed project expose sensitive receptors (schools, hospitals,

resident care facilities, or day-care centers) to substantial pollutant concentrations? This analysis should discuss the proximity of any surrounding or proposed sensitive receptors to any known point source pollutant emissions and if applicable, a health risk analysis for diesel fired PM10 (Construction phase and Operational).

5. Would the proposed project create objectionable odors affecting a substantial

number of people? 6. Any proposed dust control measures or project design elements that may be

incorporated to minimize criteria pollutant emissions should be described in the project description.

7. Staff recommends the following measure be included in the Study for ongoing

dust control during project operation: A non-toxic, biodegradable agent or permeable rock material shall be maintained on all disturbed or exposed surface areas as follows: A binding agent suitable for both traffic and non-traffic areas shall be used. These agent shall be are biodegradable, eco-safe, with liquid

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copolymers that stabilize and solidify soils or aggregates, which and facilitate dust suppression. Alternatively, a permeable rock material consisting of either river stone decomposed granite or gravel could be placed in a thin cover over all exposed surface area in-lieu of the binding agent referenced above.

A Memorandum of Understanding must be executed by the applicant and consultant and subsequently submitted with the first iteration review. G. SCOPE FOR BIOLOGICAL RESOURCES REPORT: Project Specific Information: Based on a review of aerial photos and County vegetation mapping, it appears that the project site contains the following biological habitats: semi-desert chaparral, flat-topped buckwheat, sagebrush scrub, alkali seep, open coast live oak woodland, redshank chaparral and urban/developed lands. To evaluate the impacts of the proposed project on biological resources, a Biological Resources Report is required, and must include a Biological Resources Map, as detailed below.

General Information: A Full Biological Resource Report must be prepared in accordance with the County’s Report Format and Content Requirements Biological Resources, which can be found at http://www.sdcounty.ca.gov/dplu/docs/Biological_Report_Format.pdf. The report will provide a qualitative and quantitative analysis of all on and off-site biological impacts (both direct and indirect) related to all phases of the project. The report must include a Biological Resources Map showing the location of all vegetation types and sensitive habitats and species of the project site and off-site areas being altered as a result of project implementation. The mapping guidelines are included in the Report Format and Content Guidelines at the link above. In order to evaluate impacts to sensitive resources, the most current project plot plan or preliminary grading plan must be included on the map along with proposed open space and limited building zone easements.

Staff has prepared and attached a comprehensive list of sensitive species that may exist on the project site. Directed and/or protocol surveys are required for species shown in boldface type in the list. The biology report shall address the potential for each sensitive species to occur on the project site (table format). For further guidance please see the Report Format and Content Guidelines.

DPLU has also determined that the report shall include focused survey(s) -or- site assessment for the following rare and endangered species: Quino checkerspot butterfly and spring rare plants. The focused survey(s) must be done by biologist(s) with demonstrable knowledge in field detection of the subject species (focused surveys for Federally listed species shall be in compliance with USFWS protocol, when such protocol exists, and must be done by a USFWS permitted biologist -- contact the USFWS at (760) 431-9440). If no protocol has been established, the methods of the directed search shall be described in the report. At a minimum, focused surveys must consist of walking transects across all areas with potential habitat for the species. The point locations and inferred territories of these species shall be included on the

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biological resources map. Focused surveys reports may be attached to the biological survey report in appendix form, but survey results must be evaluated in the biological survey report.

The report must also propose applicable and feasible mitigation measures. Examples are listed in Appendix A of the Report Format and Content Guidelines. Proposed Off-site Mitigation: If off-site mitigation is proposed to mitigate for significant biological impacts, please provide a statement indicating where the off-site mitigation will be located. If the off-site mitigation will be obtained in a mitigation bank, please provide the name of the bank along with evidence that such credits can be allocated for this project. If the off-site mitigation will be through the purchase and preservation of other off-site land, please provide sufficient information for staff to evaluate the off-site resources and the means to preserve the resources in perpetuity. Open Space Easements: If biological open space is proposed, please submit a project-scale Open Space Map. The Open Space Map must show what biological resources are being protected and include a table showing the area (in acres) of land preserved according to vegetation type. All Biological Open Space Easements shall be protected from future fire-clearing through the dedication of a Limited Building Zone Easement. This easement is 100 feet wide and extends outward from the Biological Open Space Easement boundary. The Limited Building Zone Easement prohibits the construction of houses, barns, or other habitable structures that would require fire clearing into the Biological Open Space. All existing and proposed open space easements (biological resource & limited building zones) must be clearly shown on the plans/map and on the preliminary grading plan. In association with any proposed open space easements, temporary and/or permanent fencing and permanent signs may be required to protect the easements. These conditions are meant to protect from inadvertent disturbance of all open space easement(s) that do not allow grading, brushing or clearing. The open space fencing/signage plan for the proposed biological open space easement must be clearly shown on the preliminary grading plan and on the Open Space Map. RPO: The project site contains a natural drainage that may qualify as a wetland under the San Diego County Resource Protection Ordinance (RPO). The Resource Protection Ordinance prohibits impacts to wetlands and wetland buffers. These natural features are a significant constraint for land uses on the project site and may affect project design. The biological information requested below is required for staff to determine project compliance with the RPO.

Wetlands Survey: A wetlands survey must be completed using the wetlands definition in the County’s Resource Protection Ordinance (RPO). The County’s definition of wetlands varies from the federal U.S. Army Corps of Engineers’ definition. All RPO wetlands shall be mapped on the Biological Resources Map using aerial photographs and a field site visit. Should there be a disagreement over the extent of wetlands, staff may require further surveys using the U.S. Army Corps of Engineers standards and guidance for conducting wetland delineations.

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The RPO requires buffers on all RPO wetlands. The biological resources map shall designate an appropriate wetland buffer width of 50-200 feet, depending on the biological resources present. The RPO prohibits impacts to wetlands and wetland buffers. Any part of the site that is a wetland and/or a wetland buffer must be placed into a dedicated Biological Open Space Easement. All Biological Open Space Easements shall be protected from future fire-clearing through the dedication of a Limited Building Zone Easement. This easement is 100 feet wide and extends outward from the Biological Open Space Easement boundary. The Limited Building Zone Easement prohibits the construction of houses, barns, or other habitable structures that would require fire clearing into the Biological Open Space. Once the wetland(s), wetland buffer(s) and limited building zone easement(s) are mapped, redesign of the proposed project may be required. Jurisdictional Resources: DPLU staff has determined that the project may disturb wetlands, lakes, streams, and/or waters of the U. S. that may require notification to the California Department of Fish and Game (CDFG) and/or the Army Corps of Engineers (ACOE). Although it is not required at this time, DPLU recommends that you contact the above agencies about the permitting requirements for potential disturbances to wetlands, lakes, streams, and/or waters of the U. S. within 30 days of this letter. If such permitting requirements are incorporated into the project at this time, it may prevent future delays or changes in the project design. CDFG general information and submittal information can be obtained through the CDFG website http://www.dfg.ca.gov/1600/notification_pkg.html or by contacting the CDFG South Coast Regional Office @ (858) 467-4251. Information for consultation and formal submittal of the 404 Permit application required by the ACOE can be obtained through their website at: http://www.spl.usace.army.mil/regulatory/ or through the general information number at (858) 674-5387. When a formal wetland delineation is requested, the ACOE 1987 Wetland Delineation Manual and supplement ―Guidelines for Jurisdictional Determinations for Waters of the United States in the Arid Southwest‖ should be used ( http://www.spl.usace.army.mil/regulatory/technical.htm).

Please be aware that the County will condition your project to provide written evidence that all required permits from these agencies have been obtained or that such permits are not required before issuing any authorization for land disturbance (e.g., grading permits). Indirect Impacts: Indirect impacts may be the result of secondary effects from direct impacts or those impacts that over time cause the degradation of a resource by changing its function, health or quality. Unlike direct impacts that are typically one-time effects, indirect impacts often continue in the long term and may actually increase. Indirect impacts commonly result from a project’s ―edge effects.‖ Edge effects from development may extend several hundred feet into adjacent open space areas, causing significant changes in species composition, diversity and abundance in those nearby lands. Projects can have a wide variety of indirect impacts depending on the nature of the project, the type of resources present, and the type and degree of edge effects. Certain restrictions may be required when the project proposes significant noise within close proximity to existing or proposed open space.

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The Memorandum of Understanding must be executed by the applicant and consultant, and subsequently submitted with the first iteration review.

Revised Comprehensive List of Sensitive Species

Pla

nt

Ani

mal

Latin Name Common Name

Dire

cted

Sur

vey

Req

uire

d

X Astragalus douglasii perstrictus Jacumba Milkvetch X

X Berberis fremontii Fremont barberry

X Caulanthus simulans Payson's jewelflower

X Delphinium parishii subglobosum Desert larkspur

X Geraea viscida Sticky geraea X

X Hemizonia floribunda Tecate tarplant X

X Heuchera brevistaminea Mt. Laguna alumroot X

X Hulsea californica California hulsea X

X Lathyrus splendens Pride of California

X Linanthus bellus Desert beauty X

X Mimulus aridus Desert monkey flower

X Pentachaeta aurea Golden-rayed pentachaeta

X Ribes canthariforme Morena currant X

X Streptanthus campestris Southern jewelflower X

X Accipiter cooperi Cooper's hawk X

X Accipiter striatus Sharp-shinned hawk X

X Antrozous pallidus Pallid bat

X Aquila chrysaetos Golden eagle X

X Bassariscus astutus Ringtail

X Buteo lineatus Red-shouldered hawk X

X Cathartes aura Turkey vulture X

X Chaetodipus californicus femoralis Dulzura California pocket mouse

X Chaetodipus fallax fallax Northwestern San Diego pocket mouse

X Corynorhinus townsendii Townsend's big-eared bat

X Crotalus ruber ruber Northern red diamond rattlesnake

X Danaus plexippus Monarch butterfly

X Diadophis punctatus similis San Diego ringneck snake

X Eumops perotis californicus Greater western mastiff bat

X Euphydryas editha quino Quino checkerspot butterfly X

X Felis concolor Mountain lion

X Lepus californicus bennettii San Diego black-tailed jackrabbit

X Melanerpes lewis Lewis' woodpecker (Winter) X

X Myotis ciliolabrum Small-footed myotis

X Myotis evotis Long eared myotis

X Myotis thysanodes Fringed myotis

X Myotis volans Long legged myotis

X Myotis yumanensis Yuma myotis

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X Nyctinomops femorosaccus Pocketed free-tailed bat

X Odocoileus hemionus Southern mule deer

X Onychomys torridus ramona Southern grasshopper mouse

X Oreortyx pictus eremophila Mountain quail

X Phrynosoma coronatum blainvillei San Diego horned lizard

X Sceloporus graciosus vandenburgianus Southern sagebrush lizard

X Taxidea taxus American badger

H. SCOPE FOR ARCHAEOLOGICAL RESOURCES: ARCHAEOLOGICAL/HISTORICAL SURVEY Project Specific Information: Staff has reviewed County records, as well as the archaeological database from the South Coastal Information Center (SCIC) at San Diego State University. This review indicates that much of the project area was surveyed previously throughout the years (Chace 1979, Clifford 03, Smith 05, and portions Hector 07). There are more than nineteen archaeological sites located on the subject parcels (three of which appear to be located in dedicated open space easements, CA-SDI-6893, CA-SDI-5933 and CA-SDI-6892). In addition there are structures that are older than 50 years within the proposed project area; however, it is unknown whether these structures are significant. The general area in which the project is located is very rich in archaeological resources. Due to recently amended CEQA guidelines (Section 15064.5) and County Significance Guidelines, effective December 2007, addressing archaeological and historic resources, and the time that has passed since the previous archaeological surveys, a County-approved archaeological consultant shall: 1) review previous documentation for adequacy; 2) resurvey the entire project area to relocate all known sites on the property; 3) determine if previously undiscovered sites can be identified; 3) prepare a new archaeological report that includes the details of the latest record search and field resurvey and 4) addresses the significance of all previously recorded sites (if relocated) and direct/indirect impacts to all archaeological sites and mitigation of those impacts as a result of the currently proposed project according to County guidelines. General Information: A field survey for archaeological artifacts and features and/or an evaluation of the site as a historic resource must be conducted in accordance with the County of San Diego Guidelines for Determining Significance – 2007 (GDS) and Report Format and Content Guidelines – 2007 (RFCG), the Resource Protection Ordinance (RPO), Section 21083.2 of the Public Resources Code (CEQA), and the San Diego County CEQA Guidelines. The survey must provide evidence in the form of a letter from the South Coastal Information Center and the Museum of Man that an institutional record searches has been conducted. In addition, a field survey and/or evaluation by a County approved archaeologist/historian must be conducted. The study shall include a copy of the blueline map/plot plan with the location of the resources plotted. The report shall follow the RFCG. Please complete all appropriate DPR Series 123 forms and submit them to the South Coastal Information Center and the DPLU. Pursuant to the RFCG, a Native American monitor shall be present during the survey phase for archaeological resources. If no cultural resources are discovered, a brief letter report will be satisfactory documentation of the survey. Guidelines for Determining Significance and Report Format and Content Guidelines can be obtained from the County website at:

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http://www.sdcounty.ca.gov/dplu/Resource/3~procguid/3~procguid.html#arch Scientific evidence must be provided to substantiate (a) the scientific and/or historical significance, and (b) the boundaries of the resource(s). If the significant resources extend off-site, these must be shown on the map and discussed. The report must address both CEQA and County RPO significance criteria for each resource as outlined in Section 3.2.2 of the GDS.

The report must address the direct construction impacts to resources (both on- and off-site) as shown on the blueline map/plot plan and make a determination as to impact severity as outlined in Section 4.2 of the GDS. The RPO provides guidance for impact avoidance. Any resource(s) that will be exposed to indirect impacts from the project should be addressed as well. All project specific archaeological/cultural site location maps and figures must be submitted under a separate cover that clearly states that the contents are not for public review. Sacred Lands Check: County staff will conduct a Sacred Lands Check with the Native American Heritage Commission (NAHC). In addition, staff will communicate with any Native American individual or organization that may possess knowledge about Sacred Sites or be affected by your project. Staff will keep you informed as to future communications with local tribes. ARCHAEOLOGICAL SIGNIFICANCE TESTING Project Specific Information: Depending on the results of the archaeological survey, significance testing may be necessary. This determination will be made once the survey report has been reviewed by the Department of Planning and Land Use. General Information: If the project design will impact cultural resources, a County approved archaeologist shall conduct scientific testing to demonstrate the significance, boundaries, and area (square meters/yards) of the resources. Pursuant to the RFCG, a Native American monitor shall be present during the significance testing phase. All testing shall use a 1/8 inch mesh or finer screens unless the use of larger mesh has been approved by the Department of Planning and Land Use. Any testing shall be approved by the Department of Planning and Land Use prior to commencing fieldwork. If the project is exempt from the RPO, significant archaeological resources mitigation should include alternatives for either (1) avoidance (preservation), or (2) data recovery. Data recovery must be conducted by a County approved archaeologist with a Department of Planning and Land Use approved research design prior to conducting fieldwork. The analysis and report shall conform to the RFCG. Pursuant to the RFCG, a Native American monitor shall be present during data recovery activities. If the project is subject to the RPO, and the cultural resources do not meet the definition of a significant prehistoric/historic site as defined in the RPO but do meet CEQA significance criteria, significant archaeological resources mitigation should consider avoidance (preservation) as the first alternative, however if infeasible, data recovery may be considered a mitigation measure. If the cultural resources do meet the definition of a significant prehistoric/historic site as defined in the RPO, avoidance is

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required. An open space easement and preservation plan will be required. All activities associated with cultural resources must be conducted by a County approved archaeologist. The analysis and report shall conform to the RFCG. PRESERVATION PLAN Archaeological Resources If significance testing produced evidence that indicates resources are to be protected pursuant to the RPO, or if preservation is the form of mitigation selected for CEQA significant sites, the project should be redesigned, if necessary, to avoid impacts and preserve the resource(s). The report should address the need to cap the resource(s) with soil, gravel, jute landscape matting, and/or leaf compost to protect the site from indirect impacts. Open space easements or other measures should also be considered to prevent future impacts to resources. HISTORIC RESOURCES If the historic resource evaluation determines that a site is significant pursuant to Section 3.2.2 of the Guidelines for Determining Significance (2007), the survey report must include a preservation plan. Adaptive reuse, open space easements, facade easements, and other conservation easements should be considered in the report. Specific performance criteria and/or easements should be proposed to guide future landowners.

The Memorandum of Understanding must be executed by the applicant and consultant and subsequently submitted with the first iteration review. I. SCOPE FOR FIRE PROTECTION PLAN: The Department of Planning and Land Use has completed review of the project design and has determined that the project may expose people or structures to a significant risk of loss, injury or death-involving wildland fires because the project is adjacent to and/or within wildlands that have the potential to support wildland fires. A Fire Protection Plan (FPP) shall therefore be prepared for the project. The Fire Protection Plan shall follow the Guidelines for Determining Significance for Wildland Fire and Fire Protection, available online at http://www.sdcounty.ca.gov/dplu/docs/Fire-Guidelines.pdf, and the County’s Report Format and Content Requirements for Wildland Fire and Fire Protection, available online at: http://www.sdcounty.ca.gov/dplu/docs/Fire-Report-Format.pdf The FPP shall be prepared by a wildland fire code expert included on the County’s list of approved consultants. The plan will include mitigation measures consistent with the unique problems resulting from the location, topography, geology, flammable vegetation and climate of the proposed site. The FPP shall also address in terms of fire code requirements: water supply, access (including secondary access where required by code), building ignition and fire resistance, fire protection systems and equipment, defensible space and vegetation management (based on site fire behavior modeling). It is recommended that you contact the County of San Diego Fire Authority (CFA) for specific requirements, codes, and regulations to be incorporated into the Fire Protection Plan prior to initiation of the Fire Protection Plan.

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The Fire Protection Plan shall meet all requirements of Section 4703 of the County Fire Code. The Plan shall also identify where any increases or decreases to the standard 100-foot fire-clearing zone are warranted. The Plan shall identify any special design elements or requirements associated with any increases in the fire-clearing zone. In addition, the Plan shall propose a mechanism whereby the (CFA) can track those lots where increases or decreases from the standard fire clearing distance of 100 feet has been approved, so that future fire clearing requirements will be consistent with approved fire clearing increases. Technical Information Report: The County Fire Authority (CFA) has requested that a technical report be included with the Fire Protection Plan Letter report. Because of the unique application of the Fire Code, the Fire Authority needs to review the electrical connection information to determine where and how the components would be isolated. As an appendix to the fire protection plan, a detailed technical report prepared by a qualified engineer, specialist, or fire safety specialty organization needs to be submitted for the proposed project. The technical report needs to address—but is not limited to—the following items:

Hazards of the proposed facilities to emergency responders.

Discussion on how to properly de-energize equipment.

Signage recommendations (provide figures for each): o At each disconnecting means depicting what equipment it de-energizes. o Each inverter structure is to be numbered and signed (To be visible from

at least 1,000 feet) o Lighted directories at each entrance depicting the overall site plan and the

locations of each numbered inverter structure (show locations on plot plan).

Recommended training for emergency personnel. Training will be provided prior to commissioning and on an as requested basis.

You may contact County Fire Marshal James Pine at (858) 495-5434 to discuss the Fire Protection Plan requirements. An evaluation of the completed Fire Protection Plan by the local fire protection district must be obtained prior to submittal of the Fire Protection Plan. The local fire protection district evaluation must be submitted to the Department of Planning and Land Use along with the Fire Protection Plan. Failure to obtain this evaluation may cause delay in the review of the FPP. The Memorandum of Understanding must be executed by the applicant and consultant and subsequently submitted with the first iteration review. The following are design features that need to be implemented on the plans. See comments in section A above related to the plot plans. An official consultation with the County CFA is required to discuss these potential requirements. Please contact James Pine at 858-495-5434: 1. Access: The driveway (fire apparatus access road) leading from Old Highway 80

to the project site entrance shall have an unobstructed improved driveway

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entrance width of not less than 24 feet of decomposed granite (DG). Fire apparatus access roads shall be designed and maintained to support the imposed load of fire apparatus not less than 50,000 lbs and shall provided with an approved surface so as to provide all weather driving capabilities. It should be designed per County of San Diego Design Standard DS-17, DS-18, or DS-19.

2. Gates: Any gates, new or existing, must meet County Fire Code Section 96.1.503.6 for automatic operation with battery backup. The gates must open immediately upon emergency vehicle strobe light activation from either direction of approach. Gates must open for vehicles moving in the direction of egress (leaving the property) when the vehicle approaches it. Gates must open on AC power failure. Gate installation must include Knox key-operated switch.

3. Sec. 96.1.605.11.4 Ground-mounted photovoltaic arrays: Ground-mounted photovoltaic array installations shall meet the requirements of sections 605.11.4.1 through 605.11.4.4.

4. Defensible space should be determined by CFA.

5. The standard hose pull length is approximately 150 feet. All project equipment and structures must have access within at least 150 feet.

6. A 24-foot access driveway road is required around the entire facility. The access driveway should be designed as stated in comments #1 and #4 above.

7. Water supply for Fire Suppression should be provided in the form of multiple water tanks or fire hydrants.

J. SCOPE FOR STORMWATER MANAGEMENT PLAN: Based on a review of the Stormwater Intake Form for Development Projects, your project is required to complete a Minor Stormwater Management Plan because you are not considered a priority development project (PDP). Please fill out the following form and provide with your submittal: Intake Form: http://www.sdcounty.ca.gov/dplu/docs/LUEG-SW.pdf

The project lies east of the Pacific/Salton (Tecate) divide and is not considered a Priority Development Project (PDP); therefore a Major Storm Water Management Plan (SWMP) is not necessary. However the project is required to submit a Minor Stormwater Management Plan. Additional information can be obtained in the following link: http://www.sdcounty.ca.gov/dpw/watersheds/susmp/susmp.html

General Information: The County’s Watershed Protection, Stormwater Management and Discharge Control Ordinance (WPO) implements the San Diego Municipal Stormwater Permit (Order R9-2007-0001) issued by the Regional Water Quality Control Board (RWQCB) on January 24, 2007, effective on March 24, 2008. The Municipal Permit regulates the stormwater and urban runoff management policies of jurisdictions in the San Diego region and details specific requirements for development projects.

WPO Link: http://www.sdcounty.ca.gov/cob/ordinances/ord9926.doc)

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Stormwater runoff that flows over impervious surfaces (i.e., roofs and pavement) picks up and carries sediments and pollutants such as pesticides, fertilizers, oils, metals, bacteria, and animal waste into our stormwater drainage systems and to our streams, rivers, lakes, estuaries and beaches. The water that enters public storm drains in San Diego (west of the Tecate Divide) drains directly to the beaches and ocean without any wastewater treatment. The requirements of the Municipal Stormwater Permit and the updated WPO were developed to manage these pollutants by promoting filtration of each project’s stormwater on site for natural cleansing by plants, soils, and microorganisms.

The WPO requires that all development projects use Low Impact Development (LID) planning and stormwater management techniques to maximize infiltration, provide retention, slow runoff, minimize the impervious footprint and constructed widths of the project, and direct runoff from impervious areas into landscaping (see Section 67.806(c)(2) of the WPO). The minimal LID requirements that you need to include in the design of your project are:

1) Disconnect impervious surfaces (from each other and from storm drains) 2) Design impervious surfaces to drain into properly designed pervious areas 3) Use pervious surfaces wherever appropriate 4) Implement site design Best Management Practices (BMPs)

K. SCOPE FOR RESOURCE PROTECTION STUDY

Project Specific Information: The project has steep slopes located onsite as well as a potential for cultural resources that could be RPO significant. A full resource protection study is required to determine that the project complies with RPO. NOTE: The Resource Protection Ordinance was just modified August 4, 2011. Please use new version.

Provide two copies of the three-color slope analysis map (0-25% one color, 25-50% another color, and 50% and above a third color).

Provide written text that demonstrates compliance with the other RPO subject areas: Wetlands, Floodways and Floodplain Fringe, Steep Slopes, Sensitive Habitat Lands, and Significant Prehistoric and Historic sites.

General Information: This study shall consist of the materials required by Form #374 available from the Zoning Counter. Form #394, Preliminary Floodplain Evaluation, is also attached. These forms can also be found on the World Wide Web at http://www.sdcounty.ca.gov/dplu/appforms/index.html.

L. DRAINAGE/FLOODING ANALYSIS:

General Information: A drainage report is required to be prepared to determine the project’s impact on the quantity and pattern of runoff to the surrounding area. The report shall also address siltation and erosion associated with the runoff. The report should describe the drainage amounts falling on the site and show how the drainage is directed on individual lots and on-site roads.

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3992-11-018 (MPA) 22-26 October 25, 2011 Rugged Solar

A CEQA Preliminary Hydrology/Drainage Study is required for this project. Additional information can be obtained in the following links. Hydrology Manual: http://www.sdcounty.ca.gov/dpw/floodcontrol/hydrologymanual.html Drainage Design Manual: http://www.sdcounty.ca.gov/dpw/floodcontrol/drainage.html A report should describe drainage structures and locate them on a project map. No development should be planned that would disrupt drainage or cause off-site flooding. Discuss potential impacts of the project and proposed mitigation measures. M. SCOPE FOR NOISE ANALYSIS: Noise Level Limits Information: A full noise technical study is required. There is insufficient information to determine whether permanent equipment and operations on-site will exceed sound level limits of the San Diego County Noise Ordinance (Section 36-404). The County Noise Ordinance does not permit noise levels that impact adjoining properties or exceed County Noise Standards, namely, San Diego County Noise Ordinance (Section 36-404). The analysis of the noise generated from the on-site substation and inverter and transformer buildings. The County Noise Ordinance does not permit noise levels that impact adjoining properties or exceed County Noise Standards. The project site as well as adjacent land uses are zoned S-92 General Rural, that allows a one-hour average sound level of 70 (dBA) for the parcels adjacent to the industrial zone and 50 decibels (dBA). In order for the Department to make a determination on the project's conformance with County noise standards, the applicant must demonstrate that the hourly average sound levels do not exceed the 70 and 50-decibel threshold at the property line, as the most stringent condition for the project. This demonstration can be included as a section to the supplemental project description document that will elaborate on the project description. As part of this section, please provide the following information: a. Manufacturers Spec Sheet for all noise producing equipment on-site that

identifies the ARI standard and/or decibel (dBA) per range. It is important to note that all noise producing sources must be included.

b. Additional plot plan that that identifies the site location of all noise sources in

relation to property lines. It is essential to address all potential noise sources on-site and to include a discussion related to openings within all surrounding walls or fences, such as driveways, fencing and gates.

c. Hours of operation and level activity at each hour. There is insufficient information to determine whether temporary construction equipment and operations on-site will exceed sound level limits of the San Diego County Noise Ordinance (Section 36-410). It shall be unlawful for any person, including the County of San Diego, to operate construction equipment at any construction site on Sundays, and days appointed by the President, Governor, or the Board of Supervisors for a public

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3992-11-018 (MPA) 23-26 October 25, 2011 Rugged Solar

fast, Thanksgiving, or holiday. Except for the property owner condition noted in Section 36.410(a), it shall be unlawful for any person to operate construction equipment at any construction site on Monday through Saturdays except between the hours of 7 a.m. and 7 p.m. No such equipment, or combination of equipment regardless of age or date of acquisition, shall be operated so as to cause noise at a level in excess of seventy-five (75) decibels for more than 8 hours during any twenty-four (24) period when measured at or within the property lines of any property which is developed and used either in part or in whole for residential purposes. To determine conformance to the County Noise Ordinance, a noise study is required and it is essential that this component of this analysis include the following information: (1). Manufacturers Spec Sheet for all noise producing equipment on-site that

identifies the ARI standard and/or decibel (dBA) per range. It is important to note that all noise producing sources must be included.

(2). Additional plot plans that identifies the site location of all noise sources in relation

to property lines. It is essential to address all potential noise sources on-site and to include a discussion related to openings within all surrounding walls or fences, such as driveways, fencing and gates.

(3). Hours of operation and activity level at each hour. The analysis shall follow the County’s Guidelines for Determining Significance for Noise available online at http://www.sdcounty.ca.gov/dplu/docs/Noise-Guidelines.pdf and the Report Format and Content Requirements for noise available online at http://www.sdcounty.ca.gov/dplu/docs/Noise-Report-Format.pdf. Corona Affect: Corona is a phenomenon associated with all energized transmission lines. Under certain conditions, the localized electric field near an energized conductor can be sufficiently concentrated to produce a tiny electric discharge that can ionize air close to the conductors. This partial discharge of electrical energy is called corona discharge, or corona. Several factors, including conductor voltage, diameter, and surface irregularities such as scratches, nicks, dust, or water drops can affect a conductor's electrical surface gradient and its corona performance. Corona is the physical manifestation of energy loss, and can transform discharge energy into very small amounts of sound, radio noise, heat, and chemical reactions. The projects proposed generation transmission lines (Gen-Tie Lines), which can generate a small amount of sound energy during corona activity. This audible noise from the line can barely be heard in fair weather conditions on higher voltage lines, and is typically immediately near the structure. During wet weather conditions, water drops collect on the conductor and increase corona activity so that a crackling or humming sound may be heard near the line. This noise is caused by small electrical discharges from the water drops. The Memorandum of Understanding must be executed by the applicant and consultant and subsequently submitted with the first iteration review. N. DEPARTMENT OF PARKS AND RECREATION REQUIREMENTS:

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3992-11-018 (MPA) 24-26 October 25, 2011 Rugged Solar

There are no trail requirements for the project. O. SCOPE FOR GEOLOGIC RECONNAISSANCE REPORT Landslides (including Rockfalls) The project is located on or within 500 feet of a ―Landslide Susceptibility Area.‖ Therefore, a Geologic Reconnaissance Report shall be prepared to evaluate any potential to expose people or structures to potential geologic hazards concerning risks of landslides (including rockfall). The report shall be prepared using the County’s approved Guidelines for Determining Significance for Geologic Hazards and conform to report guidelines in the California Board of Geologists and Geophysicists Guidelines for Engineering Geologic Reports. The guidelines can be downloaded at the following web address: http://www.geology.ca.gov/forms-pubs/engineering.pdf. The report shall be prepared by a California Certified Engineering Geologist. At a minimum, the Geologic Reconnaissance Report should include a review of topographic maps, geologic and soil engineering maps and reports (if available), stereoscopic aerial photograph review, and other published and non-published references. Aerial photographs can be useful in identifying potential landslide features. Several sets of stereoscopic aerial photographs that pre-date project site area development taken at different times of the year are particularly useful in identifying subtle geomorphic features. A field visit will likely be necessary to fill in information in questionable areas, to address the potential risk of rockfall to the project site, and to observe surface features and details that could not be determined from other data sources. Although engineering design recommendations are generally not a required component of a Geologic Reconnaissance Report, feasible measures to mitigate potential impacts from landslides (including rockfall) to levels below significance and environmental design considerations (where appropriate), should be discussed. Suspected geologic problems that cannot be evaluated except through in-depth investigation should be clearly described in the report. If the Geologic Reconnaissance Report recommends further investigation, a Geologic Investigation must be prepared. The specific requirements to be included in a Geologic Investigation will be determined by the County on a project-by-project basis. Fault Rupture The project is located within zones of faults mapped as Quaternary or pre-Quaternary by the DMG. Therefore, a Geologic Reconnaissance Report shall be prepared to evaluate any potential to expose people or structures to potential geologic hazards concerning risks of fault rupture. The report shall be prepared using the County’s approved Guidelines for Determining Significance for Geologic Hazards and conform to the California Board of Geologists and Geophysicists Geologic Guidelines for Earthquake and/or Fault Hazard Reports. The guidelines can be downloaded at the following web address: http://www.geology.ca.gov/forms-pubs/earthquake.pdf The report shall be prepared by a California Certified Engineering Geologist. The Geologic Reconnaissance Report shall include a review of topographic maps, geologic and soil engineering maps and reports (if available), stereoscopic aerial

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3992-11-018 (MPA) 25-26 October 25, 2011 Rugged Solar

photographs, and other published and non-published references. A field visit may be necessary to fill in information regarding questionable areas, and to observe surface features and details that could not be determined from other data sources. Although engineering design recommendations are generally not a required component of a Geologic Reconnaissance Report, feasible measures to mitigate potential impacts from fault rupture to levels below significance and environmental design considerations (where appropriate), should be discussed. Suspected geologic problems that cannot be evaluated except through in-depth investigation should be clearly described in the report. If the Geologic Reconnaissance Report recommends further investigation, a Geologic Investigation must be prepared. The specific requirements to be included in a Geologic Investigation will be determined by the County on a project-by-project basis. Liquefaction The project site is located within a ―Potential Liquefaction Area.‖ As a first screening, the depth to groundwater should be determined for the project site. If the highest historical groundwater level for the project site is determined to be deeper than 50 feet below the existing ground surface or proposed finished grade (whichever is deeper), no further assessment of potential liquefaction is required. For projects where the highest groundwater level for the project site is determined to be less than 50 feet, further screening of potential liquefaction is required and a Geologic Reconnaissance Report shall be prepared using the County’s approved Guidelines for Determining Significance for Geologic Hazards and follow guidelines in the California Geologic Survey’s Guidelines for Evaluation and Mitigating Seismic Hazards in California, Special Publication 117, Chapter 6 – Analysis and Mitigation of Liquefaction Hazards. These guidelines can be downloaded from the California Department of Conservation’s Geologic Survey website: http://gmw.consrv.ca.gov/shmp/webdocs/ sp117.pdf. The report shall be prepared by a California Certified Engineering Geologist. Although engineering design recommendations are generally not a required component of a Geologic Reconnaissance Report, feasible measures to mitigate potential impacts from liquefaction to levels below significance and environmental design considerations (where appropriate), should be discussed. Suspected geologic problems that cannot be evaluated except through in-depth investigation should be clearly described in the report. If the Geologic Reconnaissance Report recommends further investigation, a Geologic Investigation must be prepared. The specific requirements to be included in a Geologic Investigation will be determined by the County on a project-by-project basis. P. SCOPE FOR HYDROMODIFICATION:

The project lies east of the Pacific/Salton (Tecate) divide and is not considered a Priority Development Project (PDP); therefore, it is exempt from Hydromodification requirements.

Q. AGRICULTURAL RESOURCES:

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3992-11-018 (MPA) 26-26 October 25, 2011 Rugged Solar

The EIR should discuss Agriculture (using the County’s Guidelines for Determining Significance and Report Format and Content Requirements for Agricultural Resources) and analyze only the three Required Factors, within the County LARA Model. As we discussed, the Water Resources Required Factor will receive a Low Rating, for each project, due to their location outside the CWA and within a fractured crystalline aquifer (regardless of the existence of wells). Therefore, according to the County Guidelines, neither project will be identified as an Important Agricultural Resource and no mitigation is necessary. Please note that Rugged Solar is partially in an Agricultural Preserve (without a Williamson Act Contract). The EIR must discuss this and explain that due to: The lack of a Williamson Act Contract; The fact the site is not an Important Agricultural Resource; and That the Preserve is quite extensive (verify that Preserve is off the subject properties) continued ag within the Preserve may continue, regardless of this project.